1. 1 Iowa AWMA Meeting Kurt Shobe, MS, PG, CHMM GeoStat Environmental, LLC

2. Agenda SPCC Plan Requirements SPCC Plan Preparation SPCC Inspection

3. SPCC PLAN REQUIREMENTS 3 Who is covered by the SPCC Rule? A facility is covered by the SPCC rule if it has an aggregate aboveground oil storage capacity greater than 1,320 U.S. gallons; or a completely buried storage capacity greater than 42,000 U.S. gallons and there is a reasonable expectation of an oil discharge into or upon navigable waters of the U.S. or adjoining shorelines.

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5. What is an oil? 40 CFR 112.2: Oil means oil of any kind or in any form, including, but not limited to: fats, oils, or greases of animal, fish, or marine mammal origin; vegetable oils, including oils from seeds, nuts, fruits, or kernels; and, other oils and greases, including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with wastes other than dredged spoil. 5

6. SPCC PLAN REQUIREMENTS 6 What kinds of facilities are covered? A facility that stores, processes, refines, uses or consumes oil and is non-transportation-related is potentially subject to the SPCC rule. Operations that are intended to move oil from one location to another, i.e. transportation- related, are not included.

7. What kinds of activities are typically not covered? Here are some examples of transportation- related activities or equipment typically not covered by the SPCC rule: Interstate or inter-facility oil pipeline systems Oil transported in vessels (e.g. ships, barges) Oil transported between facilities by rail car or tanker truck 7

8. How do I calculate oil storage capacity? Use the shell capacity of the container (maximum volume) and not the actual amount of product stored in the container (operational volume) to determine whether the SPCC rule applies to you. Count only containers with storage capacity equal to or greater than 55 U.S. gallons. 8

9. Examples of oil storage containers at a facility that do count toward facility storage capacity: Bulk storage containers: Aboveground storage tanks; certain completely buried tanks; partially buried tanks; tanks in vaults; bunkered tanks; and mobile or portable containers such as drums, totes, non-transportation­ related tank trucks, and mobile refuelers. Oil-filled equipment: May include electrical or operating equipment such as hydraulic systems, lubricating systems manufacturing equipment such as process vessels, or other equipment used in the alteration, processing, or refining of crude oil and other non-petroleum oils, including animal fats and vegetable oils. 9

10. 10 How do I determine if my facility could reasonably discharge oil into or upon navigable waters or adjoining shorelines? Consider the geography and location of your facility relative to nearby navigable waters (such as streams, creeks, and other waterways). Additionally, you should determine if ditches, gullies, storm sewers, or other drainage systems may transport an oil spill to nearby streams. If you consider the applicable factors described above and determine a spill can reasonably flow to a waterway, then you must comply with the SPCC rule.

11. Who can certify the SPCC Plan? Preparation of the SPCC Plan is the responsibility of the facility owner or operator, who may also be eligible to self-certify the SPCC Plan if the facility meets the following eligibility criteria for a qualified facility: Can be self-certified if: Total aboveground oil storage capacity of 10,000 gallons or less, and: In the 3 years prior to the date the SPCC Plan is certified, the facility has had no single discharge of oil to navigable waters or adjoining shorelines exceeding 1,000 U.S. gallons, or no two discharges of oil to navigable waters or adjoining shorelines each exceeding 42 U.S. gallons within any 12-month period. Requires PE Certification: If the facility does not meet the above criteria, the SPCC Plan must be certified by a licensed Professional Engineer (PE). By certifying the SPCC Plan, the PE confirms that: PE is familiar with the requirements of the rule; PE or an agent has visited and examined the facility; The SPCC Plan has been prepared in accordance with good engineering practices, including consideration of applicable industry standards, and with the requirements of the rule. 11

12. SPCC PLAN PREPARATION 12 Part 1: Plan Administration Management Approval and Designated Person Professional Engineer Certification Plan Review Part 2: General Facility Information Facility Description Evaluation of Discharge Potential Part 3: Discharge Prevention – General SPCC Provisions 3.2 Facility Layout Diagram, including discharge volumes and direction of flow 3.3 Spill Reporting 3.5 Containment and Diversionary Structures 3.7 Inspections, Tests, and Records 3.8 Personnel, Training, and Discharge Prevention Procedures 3.9 Security

13. SPCC PLAN PREPARATION 13 Part 4: Discharge Prevention – SPCC Facility Drainage Bulk Storage Containers Transfer Operations, Pumping, and In-Plant Processes Part 5: Discharge Response Waste Disposal Discharge Notification Cleanup Contractors and Equipment Suppliers

14. 14 Appendices A: Site Plan and Facility Diagram B: Substantial Harm Determination C: Facility Inspection Checklists D: Record of Containment Dike Drainage E: Record of Discharge Prevention Briefings and Training F: Calculation of Secondary Containment Capacity G: Records of Tank Integrity and Pressure Tests H: Emergency Contacts I: Discharge Notification Form J: Discharge Response Equipment Inventory K: Agency Notification Standard Report SPCC PLAN PREPARATION

15. SPCC INSPECTION Role Of the Inspector: Official Agency representative Fact finder Technical authority Enforcement case developer (in some cases) Enforcement presence Technical educator 15

16. SPCC INSPECTION WHAT TO EXPECT Opening conference Discussion of facility operations and site specific SPCC elements Use of detailed SPCC checklist Review of Plan onsite Records review Facility walk-through Closing conference Follow-up In certain cases, enforcement 16

17. SPCC INSPECTION FACILITY WALK THROUGH Observation of tanks, piping, loading racks, transfer areas, drainage controls, security measures, etc. Discussion of SPCC implementation with staff and operators Photo documentation Interviews Inspect response equipment (Active Measures) Provide compliance assistance as appropriate Field verification of Plan elements using national inspections checklist Records review 17

18. SPCC INSPECTION CLOSING CONFERENCE Fill in information gaps Answer questions Prepare documentation (Checklists and/or inspection report) EPA is not required to leave the checklist with the facility EPA inspector does not typically provide Agency compliance determinations in the field EPA inspector may identify potential deficiencies in the field EPA inspector may provide compliance assistance as allowed by EPA policy 18

19. SPCC INSPECTION COMMON VIOLATIONS Facilities that did not know that they were regulated: Small facilities Farms Construction sites Smaller storage facilities 19

20. SPCC INSPECTION COMMON VIOLATIONS Owner/operator does not have records of inspections or tests Common to hear that they do inspections, but do not write them down No Integrity testing records/program 20

21. SPCC INSPECTION COMMON VIOLATIONS No Secondary Containment, or inadequate containment for tanks 21

22. SPCC INSPECTION COMMON VIOLATIONS No containment for non-loading rack transfer areas 22

23. SPCC INSPECTION COMMON VIOLATIONS Containment drain valve open 23

24. SPCC INSPECTION COMMON VIOLATIONS Containers lack integrity 24

25. SPCC INSPECTION COMMON VIOLATIONS 25

26. SPCC SPILL REPORTING Report to the EPA Regional Administrator (RA) when there is a discharge of: More than 1,000 U.S. gallons of oil in a single discharge to navigable waters of the U.S. and adjoining shorelines More than 42 U.S. gallons of oil in each of two discharges to navigable waters of the U.S. and adjoining shorelines within a 12- month period When making this determination, it is the amount of the discharge in gallons that reaches navigable waters of the U.S. and adjoining shorelines An owner/operator must report the discharge(s) to the EPA Regional Administrator within 60 days 26

27. SPCC REQUIREMENTS, PREPARATION, INSPECTION Questions? 27 Kurt Shobe kshobe@geostatenvironmental.com (620) 245-3836 geostatenvironmental.com